Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
The petitioner's transaction of sale of immovable property was complete in the assessment year (AY) 2005-06 through execution of agreement, receipt of consideration, and handing over possession, though the sale deed was registered in July 2008. As per Section 47 of the Registration Act, 1908, the sale deed relates back to AY 2005-06, not the date of registration. In AY 2006-07, neither sale nor registration occurred, precluding reassessment proceedings u/s 148 to determine capital gains. Consequently, the impugned order and notices were quashed by the High Court, holding that the correct assessment year was AY 2005-06 when the transaction was disclosed in the income tax returns.
The petitioner's transaction of sale of immovable property was complete in the assessment year (AY) 2005-06 through execution of agreement, receipt of consideration, and handing over possession, though the sale deed was registered in July 2008. As per Section 47 of the Registration Act, 1908, the sale deed relates back to AY 2005-06, not the date of registration. In AY 2006-07, neither sale nor registration occurred, precluding reassessment proceedings u/s 148 to determine capital gains. Consequently, the impugned order and notices were quashed by the High Court, holding that the correct assessment year was AY 2005-06 when the transaction was disclosed in the income tax returns.
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